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V0046-26 13 January 2026 · SG de Impuestos sobre las Personas Jurídicas Criterion in force
IS · precio de adquisición

Rental income-linked contingent payments may increase fixed asset value

A company asked whether upward adjustments to property purchase price based on rental income should be considered as increased asset cost for amortisation. The DGT states that, under accounting rules, contingent payments based on rental income may be included in acquisition cost, while other indicators require greater detail.

The question raised

Whether an upward adjustment to the purchase price, whether linked to gross income obtained from leasing during the marketing period, or to other variables (occupancy percentage and service costs, among others), must be considered as a higher value of acquired fixed assets, with the annual depreciation for the portion corresponding to the construction being tax deductible as established in Article 12 of the Corporate Income Tax Law, 27/2014, hereinafter LIS.

The DGT's ruling

The acquisition price of a building includes the best estimate of the current value of contingent considerations. If the contingent payment is linked to rental income during the marketing period, it appears possible to consider it as a higher acquisition price. Changes in this estimate shall be applied prospectively, modifying the depreciation installments. Depreciation shall be deductible provided that it corresponds to the effective depreciation of the asset.

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